W000528
Sunday, November 25, 2001 12:56 PM
comments on rules for Sept. 11 Victim Compensation Fund
To Whom it May Concern:
I am writing to provide my comments on the current proposal for the
September 11 Victim Compensation Fund. I would first like to express my
appreciation that such efforts have been initiated and that public
comment has been requested. Unfortunately, these issues are very dear
to me, because I lost my father, who was working at One
World Trade Center on September 11th.
I read the proposed regulations quite closely and feel that much of the
plan for the Victims' Compensation Fund is fair to the victims and their
families. Specific comments on various topics follow. I am most
concerned, however, with the definition of "collateral source funds"
(Topic 6): I believe that families' compensation *should not* be
reduced by the amount of supplemental life insurance received. Such a
reduction would punish those victims who sacrificed earlier earnings to
offer their family extra security. Certainly, we do not want these
earlier sacrifices by the victims to result in less funds being obtained
by their family members. In addition, we do not want to discourage
others from planning in the future for their heirs.
Topics 1&2:
· If the claimant is to submit an amount of compensation sought, rules,
schedules, and/or formulas should be published for determining
compensation due. This would lessen the burden on those claimants
unable to pay for attorney or expert help in filing (also pertains to
topics 4 and 6).
· If the Special Master should determine that insufficient information
is available to determine a claim, the claim should be considered as
"not filed."
Topic 3:
· The claimant should be given the opportunity to clarify information if
required before final determination is made or to refile the claim with
additional supporting information.
· Every claimant need not be granted an oral hearing; this would be
cumbersome to all involved. However, the claimant should reserve the
right to request such a hearing or appeal to the Special Master if the
results of the paper hearing are unsatisfactory.
Topic 6:
· Definition of "collateral sources":
· Supplemental insurance paid for by the victim or victim's family
should not be considered collateral source. Families should not be
penalized for preparing for unexpected events.
· Pension fund should be included only if pension earnings are included
in the "economic loss" schedules.
· Charitible contributions should not be included. Citizens who donated
monies to charities to help victims and their families expect that
government compensation be administered without respect to private aid.
Please consider these comments when you develop the final rules for the
Fund. Thank you once again for seeking the input of the public.
Sincerely,
Individual Comment
Tucson, AZ